The stablecoin market is rapidly developing, and the global regulatory landscape is gradually taking shape.

Regardless of how it is judged, in terms of practical application, the current crypto world is fundamentally no different from 5-10 years ago. Although the scale continues to grow and DeFi has become a major highlight, ultimately, the most successful applications in the crypto market are still currency-related, with stablecoins being the most notable apart from Bitcoin.

Although both types of cryptocurrencies have achieved widespread use, their development paths are completely different. Bitcoin has gained global recognition due to its astonishing price increase, becoming the representative of decentralized currency. However, from the perspective of practicality rather than value storage, stablecoins are the true crypto assets that have achieved large-scale global adoption.

The current global stablecoin market capitalization has reached 243.8 billion USD. According to data platform statistics, the total trading volume of stablecoins in the past 12 months has reached 33.4 trillion USD, with the number of transactions reaching 5.8 billion and the number of active unique addresses reaching 250 million.

High usage frequency and large scale indicate that the demand and logic for stablecoin applications have basically matured. However, from a regulatory perspective, stablecoins are still in the adjustment phase. In recent years, global stablecoin regulation has continued to improve. The U.S. Senate has just passed the "Guiding and Promoting American Stablecoin Innovation Act" (GENIUS Act ), which clears obstacles for global stablecoin regulation once again.

The development of stablecoins is rapid, and the head effect is significant.

Stablecoins provide value stability by being pegged to underlying assets such as fiat currencies and precious metals, aiming to eliminate the high volatility of cryptocurrencies and provide users with reliable settlement, storage, and investment tools. As a measure of value in the crypto market, every expansion of stablecoins reflects the growth of the industry scale. In 2017, the global circulation of stablecoins was less than $1 billion, and it has now approached $250 billion. Meanwhile, the global crypto market has grown from less than $1 trillion to a scale of $3 trillion, gradually entering the mainstream.

From recent data, this bull market can be seen as a stablecoin bull market. After the FTX incident, the global supply of stablecoins dropped from $190 billion to $120 billion, but has since steadily increased, continuing to rise over the past 18 months. Meanwhile, the price of Bitcoin has climbed from a low of $17,500 to over $100,000. The reason behind this is that the liquidity in this bull market mainly comes from external institutions, and institutions typically prefer to use stablecoins as a medium when entering the market, thus reflecting an increase in external liquidity and an expansion in the scale of stablecoins.

As of now, there are a wide variety of stablecoins. They can be categorized into centralized and decentralized stablecoins based on their control centers, classified as USD stablecoins and non-USD stablecoins based on fiat currency type, and further divided based on interest-bearing status, types of collateral, etc., covering a broad range. Unlike other crypto assets, stablecoins are essentially core pricing tools, not used for speculation, mostly without official restrictions, and globally available, laying the foundation for them to become a global currency.

In terms of coverage, emerging markets such as Brazil, India, Indonesia, Nigeria, and Turkey, especially in regions with weak financial infrastructure and severe inflation, have begun to use stablecoins in everyday transactions, in addition to mainstream regions like Europe, the United States, Japan, and South Korea. According to a report from a payment platform last year, the most popular use of stablecoins outside of the crypto field is as a currency substitute (69%), followed by payments for goods and services (39%) and cross-border payments (39%).

It can be seen that stablecoins have begun to break away from the label of crypto investment and have become an important entry point for the integration of the crypto market and the global economy. Against this backdrop, the development pattern of global stablecoins has attracted significant attention. In terms of market share, USD stablecoins account for 99% of the stablecoin market, colloquially referred to as the "USD branch."

Specifically, due to the scale effect of the currency itself, the strong become stronger, and the obvious trend towards concentration is a key feature in the stablecoin field. Centralized stablecoins dominate, with a certain centralized stablecoin becoming the absolute leader, capturing a market share of 152 billion USD, accounting for 62.29%. The second-ranked centralized stablecoin has a market capitalization of about 60.3 billion USD, accounting for 24.71%. Together, these two stablecoins account for over 80% of the total market, indicating a significant concentration. The third place is taken by a certain semi-centralized stablecoin that stands out with its unique mechanism and high yield, currently having a market capitalization of 4.9 billion USD. Since the collapse of a certain algorithmic stablecoin, algorithmic stablecoins have declined, and in the ranking of stablecoins, only a decentralized stablecoin in a certain ecosystem still ranks high, with a market capitalization of about 3.5 billion USD. A well-known decentralized stablecoin has been affected by diversion, currently having a scale of only 4.5 billion USD. From the perspective of public chains, Ethereum holds an absolute dominant position, with a market share of 50%, followed by a certain public chain (3 1.36% ), a certain public chain (4.85% ), and a certain public chain (4.15% ).

From a business perspective, the issuance of stablecoins is a low-risk, high-reward business. Large-scale issuance allows the issuing institution's marginal cost to approach zero, and the model of direct exchange of digital currency for cash enables issuers to reap substantial profits from risk-free returns. Taking a well-known stablecoin issuer as an example, according to its full-year financial report for 2024, the company achieved a net profit of $13.7 billion within a year, and the group's net assets soared to $20 billion, while the company had only 165 employees, demonstrating astonishing efficiency per capita. Such high returns have attracted major institutions to enter the market, and in recent years, traditional financial institutions and internet companies have been actively laying out in this field. Currently, a project from a political figure's family has also launched a stablecoin, which soft-launched on April 12 and has quickly integrated over 10 protocols or applications.

Regulatory Adjustment Accelerates, U.S. Senate Passes the GENIUS Act

With institutions rushing in, regulation has followed. Currently, places like the United States, the European Union, Singapore, Dubai, and Hong Kong have either begun or completed legislation regarding stablecoins. As a crypto hub, the United States is undoubtedly the most watched region in the world.

From the perspective of U.S. regulation, stablecoins have undergone a process from high uncertainty to gradual clarity. Before 2025, the U.S. Congress did not enact specific regulations regarding stablecoins and cryptocurrencies. Under the existing regulatory framework, multiple regulatory agencies have defined stablecoins in an effort to gain dominance in this emerging field. One law enforcement agency regulates entities engaged in cryptocurrency issuance and trading through a licensing system, while another regulatory agency considers some stablecoins as securities under the Securities Exchange Act, and a different regulator focuses on stablecoins from a commodities perspective concerning anti-fraud and anti-market manipulation. This complex regulatory system not only makes it difficult to define entities but also presents a trend of diversification at the state level under the U.S. administrative system, with some states even having independent cryptocurrency licenses.

It can be seen that the regulation of stablecoins before 2025 is quite fragmented, and there are even chaotic phenomena caused by the struggle of regulatory agencies, leading to high uncertainty and compliance challenges in the stablecoin industry. However, with the new government taking office, the regulation of stablecoins has been accelerated.

In February of this year, the chairman of the relevant committee of the U.S. House of Representatives submitted the "2025 Stablecoin Transparency and Accountability Promotion Ledger Economy Act" (, referred to as "STABLE" ). In the same month, several senators jointly proposed the "Guidance and Establishment of the National Innovation for U.S. Stablecoins Act" (, referred to as the GENIUS Act ).

The simultaneous introduction of the two bills is not coincidental, but a forward-looking action supported by senior officials. During the first cryptocurrency summit held at the White House in March this year, the President expressed interest in stablecoins, calling them a "promising" growth model, and hoped that Congress could submit the relevant legislation to the President's office before the August recess, sending a clear signal.

On March 17, the Senate Banking Committee passed the GENIUS Act with bipartisan support, 18 votes in favor and 6 against, officially submitting it to the Senate. On March 26, the STABLE Act was submitted in revised form and was passed by the House Financial Services Committee on April 3, submitted to the House for a full vote.

Although both are stablecoin bills, their focuses are slightly different. STABLE prioritizes federal unified control, while GENIUS emphasizes building a dual-track system parallel to state and federal levels. STABLE restricts issuance qualifications to insured deposit institutions and federally approved non-bank entities, whereas GENIUS allows for more types of entities to participate. Both require a 1:1 reserve and monthly disclosures, but STABLE is stricter, requiring additional insurance and imposing a two-year ban on algorithmic stablecoins, while GENIUS allows exploration of algorithmic stablecoins under specific conditions. Furthermore, GENIUS supports providing interest to stablecoin holders, while STABLE explicitly prohibits interest payments.

In practice, both bills face multiple criticisms. State governments oppose the federal regulatory priority in stablecoins, and some industry insiders express dissatisfaction with the stringent provisions. Genius has mainly sparked discussions on compliance costs, arguing that a dual-track system will increase costs and is overly focused on the domestic U.S. market, neglecting the needs of third world countries.

Currently, it seems that the GENIUS Act is progressing faster. On May 9, the Senate's first vote failed with 48 votes in favor and 49 votes against, due to opposition demands to strengthen anti-corruption provisions and prohibit members of the executive branch from holding cryptocurrencies. In response to this, the Treasury Secretary expressed dissatisfaction, stating that lawmakers are doing nothing.

Not long after, the GENIUS Act made a second attempt. The updated version introduces a regulatory mechanism based on asset scale, with stablecoins over 10 billion in assets regulated by the federal government, while those under a market value of 10 billion are regulated by individual states. It also clearly separates from U.S. insurance credit and government credit, reducing systemic risk and adding restrictions on the participation of technology companies. While it still does not address the ethical standards that the opposition party is concerned about, there has been progress in protecting investors and existing mechanisms. Against this backdrop, some opposition party members have shifted to support, and on the evening of the 19th, the U.S. Senate passed the procedural motion for the GENIUS Act with a vote of 66 in favor and 32 against, clearing the way for final legislation. The next step will be to enter the full Senate debate and amendment process, followed by review by the House of Representatives. Considering that the threshold for passage in the House is relatively low, the likelihood of the bill ultimately being submitted to the president for signing into law is quite high.

The passage of this bill is undoubtedly an important milestone in the history of cryptocurrency assets in the United States, filling the regulatory gap for stablecoins, clarifying regulatory bodies and rules, and further promoting the development of the U.S. stablecoin industry, adding momentum to the mainstreaming of the crypto industry. From the U.S. perspective, after the introduction of the regulations, the influence of the U.S. dollar deeply penetrating through stablecoins will become more prominent, and the trend of the crypto market becoming subordinate to the U.S. dollar will continue to strengthen, providing a core driver for building centralized and decentralized hegemony for the U.S. dollar. It is worth noting that regardless of the type of bill, stablecoin holders are required to hold U.S. Treasury bonds, U.S. dollars, etc., which also creates new sustained purchasing demand for U.S. Treasuries.

Outside the United States, global stablecoin regulation has begun to take shape

Clear stablecoin regulation will only be established in 2025, indicating that the United States is not at the forefront in this area. In fact, the European Union launched the ( MiCA ) bill before the United States, providing a comprehensive regulatory framework for all crypto assets, including stablecoins. MiCA categorizes stablecoins into asset-referenced tokens and electronic money tokens, similarly prohibiting algorithmic stablecoins, and mandates that issuing institutions (, especially those with a certain market scale, must maintain a 1:1 capital reserve, comply with transparency rules, and register with EU regulatory authorities. Meanwhile, the European Insurance and Occupational Pensions Authority recommends implementing strict capital management systems for insurance companies holding crypto assets ), including stablecoins (, requiring a 100% capital adequacy ratio for such asset holdings and treating them as zero-value assets in solvency calculations.

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Outside the European Union, Hong Kong is also a pioneer in stablecoin regulation. On December 6, 2024, the Hong Kong government released the "Stablecoin Regulation Draft" and submitted it to the Legislative Council for a first reading on December 18. According to the latest news, the bill will be on May 21.